Simplified due diligence: who it’s really for, and why it almost certainly isn’t you.

Last updated: 23 August 2026

Two simplifications, often confused

Before anything else, name the two things, because most of the confusion online comes from treating them as one:

• Article 13: simplified due diligence. A route tied to country benchmarking: if your origin is classified low risk, you may skip two of the due-diligence steps. It is available to operators generally, importers included.
• The 2025 “simplified declaration.” A narrower carve-out from the late-2025 simplification package, aimed at small and micro primary operators: broadly, producers placing on the market goods they grew themselves. It is not an importer’s route.

Article 13 is about where your goods come from (a low-risk country). The 2025 simplified declaration is about who you are (a small primary producer). An EU importer of someone else’s coffee or cocoa is asking the second question, and the answer is usually no.

Article 13: what it lifts

Take the one importers can actually use first. Article 13 of Regulation (EU) 2023/1115 provides:

“When placing relevant products on the market or exporting them, operators shall not be required to fulfil the obligations under Articles 10 and 11 … [where] they have ascertained that all relevant commodities and relevant products have been produced in countries or parts thereof that were classified as low risk in accordance with Article 29.”

So the whole of what Article 13 removes is the obligation to carry out Article 10 (risk assessment) and Article 11 (risk mitigation) for goods produced in a low-risk country. That is a real saving: the assessment-and-mitigation loop is the analytically heaviest part of the process for a standard-risk origin. But notice how narrowly it is drawn: two named steps, and only when all the goods in question come from low-risk origins.

What Article 13 keeps: all of it

Here is where the word “simplified” misleads. Everything Article 13 does not name stays exactly as it was. In particular:

• Information collection under Article 9, including plot geolocation. The heart of the file is untouched. You still collect the geolocation of every plot, the country and region, quantities, supplier details and the production dates, and keep the evidence. Simplified due diligence is not a geolocation exemption. (The detail is in the geolocation requirements.)
• The due-diligence system (Article 8/12). You still maintain the system and review it.
• The Due Diligence Statement. You still submit a DDS in TRACES before placing the goods, with the geolocation in it.
• Five-year record-keeping. The file still has to be retained and producible on request.

Simplified due diligence removes the analysis, not the evidence. You still gather the plot geolocation and you still file the statement. You are simply not required to run the formal Article 10/11 loop on top.

The conditions attached to Article 13

The route is also not automatic just because a flag on a map is green. Article 13 makes it conditional, and the condition is about mixing and circumvention. Before you may use it, you must have “assessed the complexity of the relevant supply chain and the risk of circumvention… or the risk of mixing with products of unknown origin or origin in high-risk or standard-risk countries,” and you must be able to “make available to the competent authority upon request relevant documentation demonstrating that there is a negligible risk” of that mixing or circumvention.

For real coffee and cocoa chains that bites. If a low-risk-origin lot is blended, at any point, with beans of unknown origin or from a standard-risk country (a common reality in aggregated, cooperative or re-exported supply), the negligible-mixing condition is no longer obviously met, and the simplified route may not be open to that lot at all. You have to be able to show, with documentation, that the low-risk provenance held all the way through.

The 2025 “simplified declaration”, not for importers

The other simplification is the one importers most often ask about, usually having read a headline about the EU “cutting EUDR red tape” in late 2025. It is real, but it is aimed somewhere else.

The simplified declaration is restricted to small and micro primary operators: essentially producers placing on the market goods they produced themselves, in countries benchmarked low risk. For that narrow group it allows a lighter, in effect one-off, declaration and, notably, the use of a postal address in place of full plot geolocation.

An EU business importing someone else’s coffee or cocoa is not a primary operator. So the simplified declaration (and its geolocation relief in particular) does not reach you, regardless of how the origin country is benchmarked.

This is the single most consequential misunderstanding we see, and it is worth being blunt about: if you buy green coffee or cocoa from a non-EU supplier and place it on the EU market, you are on the full path with plot geolocation. A low-risk origin may open Article 13 simplified due diligence to you, but never the primary producer’s geolocation exemption. We set out who the carve-out really covers in the FAQ, and why geolocation is unavoidable for importers in the geolocation guide.

So which, if either, applies to you?

Run yourself through it honestly:

• Do you produce the coffee or cocoa yourself? Almost no EU importer does. If not, the 2025 simplified declaration is out. You are not a primary operator.
• Is every origin in the consignment low risk? Check each one against the current benchmarking list. If any origin is standard or high, Article 13 is out for that lot. It’s all-or-nothing.
• Can you show negligible mixing risk? If the low-risk lot is demonstrably kept separate and traceable, Article 13 is available. If it’s blended with unknown or higher-risk product, it may not be.

For most of our clients the result is the ordinary one: no primary-producer exemption, and Article 13 available only for the slice of their sourcing that is wholly low-risk and cleanly traceable. The bulk of a typical coffee or cocoa importer’s volume runs on full due diligence, which is exactly what to plan around.

You can lose it, too

One last point that rarely makes the summaries: simplified due diligence is a privilege the regulation can withdraw. Among the penalties for serious or repeated infringement, Article 25 lists “prohibition from exercising the simplified due diligence set out in Article 13.” So even where the route is open, treating it as a licence to keep a thinner file is a poor bet: the moment something goes wrong, it can be the first thing you lose, on top of the other penalties.

The honest takeaway

Simplified due diligence is a genuine, useful provision: for the right operator, sourcing wholly from low-risk origins, with a clean chain. It is not a shortcut around the two things that actually cost time and carry risk: getting the plot geolocation and producing a defensible file. Those you keep on every path the regulation offers a coffee or cocoa importer.

This is the work we do, and we scope it to your real situation rather than the most hopeful reading of it. We check how each of your origins is benchmarked, tell you honestly where Article 13 is and isn’t available to you, collect the plot data either way, run a type-aware deforestation screen that won’t confuse shade-grown agroforestry with clearing, and assemble the evidence file behind a defensible conclusion, then, if you want, file the statement in TRACES under your operator identity. What we do not do (what no service and no simplification honestly can) is take on the legal responsibility, which stays with you as the operator. The full shape of the duty is in the complete importer guide; the method is on how it works.